Defense counsel wasn’t ineffective for not raising Riley before it was decided, and the case was tried just before Riley. Once Riley was issued, defense counsel tried to get it into the case by a motion for new trial. Other cases in Tennessee already hold failure to predict Riley wasn’t IAC. Alberts v. State, 2019 Tenn. Crim. App. LEXIS 570 (Sept. 16, 2019).
There was reason for defendant’s stop, and the stop produced the smell of marijuana and its recent use, and that was probable cause for a search of the car. State v. Hope, 2019-Ohio-3719, 2019 Ohio App. LEXIS 3793 (12th Dist. Sept. 16, 2019).*